ID: nht91-2.30

DATE: March 13, 1991

FROM: Jamie McLaughlin Fish -- Director, Intergovernmental Affairs, NHTSA

TO: Bill McCollum -- U.S. House of Representatives

TITLE: None

ATTACHMT: Attached to letter dated 6-18-81 from Frank Berndt to Roy Littlefield (Std. 119); Also attached to letter dated 1-7-90 from Perry E. Faulkner to William "Bill" McCollum

TEXT:

Thank you for your inquiry on behalf of your constituent, Mr. Perry Faulkner. Mr. Faulkner requested a written interpretation about whether casings imported into this country are required to have the "DOT number." A "casing" means a used tire to which additional tread may be attached for the purpose of retreading. As explained more fully below, casing for retreaded passenger car tires must have the DOT symbol, but casings for tires for use on vehicles other than passenger cars (referred to as "truck tires" in this letter) are not required to have the DOT symbol.

At the outset, I note that Mr. Faulkner's letter stated that the "DOT number" on a tire indicates that the Federal excise tax has been paid. That statement is inaccurate. The "DOT number" on a tire only represents the manufacturer's or retreader's certification of compliance with this agency's standards and regulations. If Mr. Faulkner wants further information about Federal excise taxes on tires, he may wish to contact the Internal Revenue Service, since that agency administers the Federal excise taxes.

Mr. Faulkner is mixing two different types of markings when he refers to a "DOT number." The first type of marking is the symbol "DOT." This marking by a tire manufacturer or retreader on a tire is a certification that the tire complies with an applicable Federal motor vehicle safety standard. Federal safety standards applicable to tires include Standard No. 109 for new passenger car tires, Standard No. 117 for retreaded passenger car tires, and Standard No. 119 for new truck tires.

Standard No. 117 (the retreaded passenger car tire safety standard) includes a requirement that all passenger car tire casings to be retreaded must include the symbol "DOT." See S5.2.3(a). Therefore, it is illegal to sell or import into this country any passenger car tire casings that are not marked with the symbol "DOT." However, none of our Federal safety standards set forth requirements for retreaded truck tires. Since there is no standard for retreaded truck tires, there is no requirement that casings for retreaded truck tires be marked with the DOT symbol. I have enclosed a June 18, 1981 letter to Mr. Roy Littlefield that offers a more detailed discussion of this issue.

The second type of marking to which Mr. Faulkner referred was the tire identification number specified in Part 574. This number identifies the manufacturer or retreader of the tire, along with the date of manufacture or retread and other attributes of the tire. A tire identification number is not required on any casing: Standard No. 117 does not require this marking on passenger car casings, and as explained above, there is

no Standard for casings for truck tires. Please note, however, that Part 574 requires all finished retreads, including retreaded truck tires, to be marked with the retreader's identification number.

I hope this information is helpful. Please let me know if you have any further questions or need some additional information on this subject.

ID: nht91-2.31

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 2-11-91 from Delbert N. Pier to Paul Jackson Rice (OCC 5720)

TEXT:

This is in reply to your letter of February 11, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108.

ID: nht91-2.32

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Loren Thomson -- Thomson & Weintraub

TITLE: None

ATTACHMT: Attached to letter dated 9-14-90 from Loren Thomson to Dorothy R. Nakama (OCC 5213)

TEXT:

This responds to your letter to Dorothy Nakama of my staff in which you asked for an explanation of the responsibilities of installers and repairers of motor vehicle glazing. I apologize for the delay in this response. In as subsequent telephone conversation with Ms. Nakama, you asked that we provide a response to the following two questions:

1) Would it be a violation of Federal law if, after fixing a broken or cracked windshield, an aftermarket business still did not make the wind- shield comply with Federal Motor Vehicle Safety Standard No. 205?

2) What would be the consequences if an installer knowingly installed in a motor vehicle new glazing that did not comply with Standard No. 205?

Your questions are addressed below.

By way of background information, section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act, 15 U.S.C. 1392) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards for new motor vehicles and new motor vehicle equipment. One of the safety standards we have issued under this authority is Standard No. 205, Glazing Materials (49 CFR S571.205). Standard No. 205 establishes performance requirements for all windows (called "glazing" in the standard) in new motor vehicles and for all new replacement windows for motor vehicles.

Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that no person may manufacture, import. sell, or introduce into interstate commerce any new vehicle or new replacement window that does not conform with the performance requirements of Standard No. 205. Pursuant to section 108(b)(1) of the Safety Act (15 U.S.C. 1397(b)(1)), this prohibition no longer applies to the motor vehicle after the vehicle is sold to a consumer. However, both before and after the first sale to a consumer, section 108(a)(2) of the Safety Act (15 U.S.C. 1397(a)(2)) provides that: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . . "

Your first question asked whether it would be a violation of Federal law if, after fixing a broken or cracked windshield (by repairing instead of replacing it), an aftermarket business still did not make the windshield comply with Federal Motor Vehicle Safety Standard No. 205. The answer depends upon whether or not the vehicle with the broken or cracked

windshield has already been sold to a consumer.

If the vehicle has not yet been sold to a consumer, the "aftermarket business" would violate section 108(a)(1)(A) of the Safety Act if the vehicle with the repaired or replaced windshield did not comply with Standard No. 205 in all respects. As noted above, that section of the Safety Act prohibits any person from manufacturing, selling, importing, or introducing into interstate commerce any new vehicle that does not comply with Standard No. 205. Thus, even if a windshield is broken while a vehicle is being delivered from the factory to a new car dealer, the windshield that is in the new vehicle when it is delivered to the first purchaser must meet all requirements of Standard No. 205.

Once the vehicle has been sold to a first purchaser for purposes other than resale, any repairs or replacement of the windshield would not violate the "render inoperative" prohibition in the Safety Act. I have enclosed a September 3, 1981 letter to the National Glass Dealers Association explaining that NHTSA does not consider repairing a damaged windshield to constitute rendering inoperative with respect to Standard No. 205, EVEN IF the repaired windshield does not meet the requirements of the standard once repaired. This is because the agency considers the object or event which damaged the windshield in the first place, not the repair shop, to have rendered the windshield inoperative with respect to Standard No. 205. Upon reconsideration, we reaffirm this interpretation.

Your second question asked about the consequences of an installer knowingly installing in a motor vehicle new glazing that did not comply with Standard No. 205. This would be a violation of section 108(a)(1)(A) of the Safety Act, because the installer would be introducing into interstate commerce an item of motor vehicle equipment (the windshield) that did not comply with the applicable safety standard. By so doing, the installer would be subject to a civil penalty of up to $1,000 for each time it installed a noncomplying windshield, per section 109 of the Safety Act (15 U.S.C. 1398).

I hope this information is helpful. If you have further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-2.33

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William F. Canever -- Staff Attorney, Office of General Counsel, Ford Motor Company

TITLE: None

ATTACHMT: Attached to letter dated 6-1-90 from William F. Canever to Stephen P. Wood (OCC 5713)

TEXT:

This responds to your letter concerning Ford's plan to allocate MY 1986 light truck credits to cover MY 1985 and MY 1989 shortfalls. For each of those model years, manufacturers have the option of complying with separate 4x4 and 4x2 standards or a combined standard. Ford elected to comply with the separate standards for MY 1985 and the combined standard for MY 1986 and MY 1989. The MY 1986 credits are applied in the plan on a prorated basis to MY 1985.

In response to your letter, we have reviewed Ford's credit allocation plan in light of 49 CFR S 535.4(e). That section provides, among other things, that "(c)redits may not be applied between classes of light trucks, except as determined by the Administrator to account for changes made in the definitions of classes between model years." Since Ford's plan involves applying credits earned by exceeding the MY 1986 combined standard to shortfalls incurred against the MY 1985 separate 4x4 and 4x2 standards, we have considered whether the plan represents a cross-class application of credits that is prohibited by S 535.4(e). As discussed below, we have concluded that Ford's allocation plan is not prohibited.

In your letter, you suggest that the regulatory scheme creates two methods of complying with light truck CAFE standards and not three classes of light trucks. You also state that the term "class" is nowhere applied to the combined light truck fleet. You conclude that there is no cross-class application of credits.

We do not agree with your suggested analysis. Section 535.3(a)(4) states that the term "class of light trucks" is used in accordance with the determinations in Part 533 of this chapter. Section 535.4(b) then indicates that credits are earned "whenever the average fuel economy for a class of light trucks manufactured by a manufacturer exceeds an applicable average fuel economy standard established in Part 533 of this chapter." The term "class" in Part 535 thus refers to each possible grouping of light trucks that is averaged together for determining compliance with CAFE standards. Looking at Part 533, there are, in fact, six classes of light trucks for the model years in question: (1) Combined captive import, (2) Combined other, (3) 2-wheel drive captive import, (4) 2-wheel drive other, (5) 4-wheel drive captive import, and (6) 4-wheel drive other.

While we do not agree with your suggested analysis, we believe that there is ambiguity with respect to how S 535.4(e) applies to the factual sitation at issue. First, Ford's plan involves overlapping classes.

Thus, while there is a degree of cross-class application of credits, it is limited. Second, NHTSA has never addressed in rulemaking the issue of

whether manufacturers should, in effect, forfeit credits as a result of choosing particular compliance options for particular years. This situation is analagous in some respects to the issue of whether forfeiture of credits should occur where NHTSA changes the definitions of classes between model years. In that situation, the agency decided, based on its understanding of statutory intent, against forfeiture. Third, in a letter dated April 26, 1988, NHTSA approved a Ford carryback plan for MY 1985 light trucks which set forth Ford's proposed allocation methodology. While the agency did not expressly address that methodology in the letter approving the plan, Ford could have assumed that the agency considered the proposed allocation to be permissible.

Given the ambiguity surrounding this issue, NHTSA believes that it is appropriate to decide the issue, for now, in favor of the manufacturer. The agency believes that this is a type of ambiguity that should be resolved, for the future, by rulemaking. However, the issue will become moot, at least for the time being, since, beginning with the MY 1992 light truck CAFE standards, NHTSA decided not to set optional separate two-wheel drive and four-wheel drive standards. Should the agency decide to issue optional CAFE standards at some future time, it will address this issue in rulemaking.

For now, NHTSA will treat situations where a manufacturer changes compliance options between model years in the same manner as situations where the agency changes the definitions of classes between model years. In both types of situations, NHTSA will follow the policy first announced in a November 8, 1979 notice of interpretation (44 FR 64943), and reaffirmed in a December 18, 1980 Federal Register notice (45 FR 83233), of attempting to assure that credits are applied to offset shortfalls on the same types of vehicles which generated the credits.

Ford's plan to apply, on a prorated basis, credits earned by exceeding the MY 1986 combined standard to shortfalls incurred against the MY 1985 separate 4x4 and 4x2 standards, is consistent with the examples set forth in the November 1979 and December 1980 notices. Ford's plan then to apply remaining MY 1986 credits to its MY 1989 shortfall, incurred against the MY 1989 combined standard, does not involve any cross-class application of credits. I therefore conclude that Ford's allocation plan is not prohibited.

ID: nht91-2.34

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: George Smyth -- Municipal/Refuse Fleet Sales, Palm Peterbilt-GMC Trucks, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7-30-75 from Richard B. Dyson (signed by Z. Taylor Vinson) to Byron A. Crampton; Also attached to letter dated 8-27-68 from Eugene B. Laskin to Barry G. Seitz (Std. 203; Std. 204); Also attached to letter dated 3-4-68 from George C. Nield to Earl Allgaier; Also attached to letter from Joseph R. O'Gorman to Nathan Darby

TEXT:

This responds to your letter requesting an opinion on the legality of modifying left-hand drive trucks by adding right-hand drive. I apologize for the delay in our response.

We assume that your question is directed towards municipal refuse trucks. Because of budget constraints, we understand that refuse trucks with dual controls are increasing in popularity because they allow one-man trash collection, rather than the two or three man crews on older trucks, and that 3,000 to 4,000 such trucks are manufactured annually. We also understand that about 80% of these trucks are equipped with a fold-down seat at the auxiliary driving position, and that the right hand driving position is used in start-stop slow speed operation in residential neighborhoods, while the left hand position is used in driving to and from work sites.

According to your letter, the trucks are manufactured with left-hand drive only, and are then modified by body companies for the end user. The modification, as we understand it, is to add a steering wheel to the right-hand side, along with an accelerator, brake pedal, horn, hazard warning, and turn signals. This indicates that the vehicle may be operated from both sides. You commented that "the unsafe part of the conversion, as we see it, is that the windshield wiper controls, parking brake, start and stop switch, along with all gauges are on the lefthand side out of reach when the driver is in the drivers position." The following represents our opinion based on the facts provided in your letter.

Standard No. 101, Controls and Displays, specifies requirements in relation to the driver. It requires that if certain controls are furnished, they must be operable by the driver, and that if certain displays are furnished, they must be visible to the driver. See section S5.1. (Since your letter concerns trucks, it should be noted that Standard No. 101's display requirements do not apply to vehicles with a GVWR of 10,000 pounds or higher.) However, Standard No. 101 does not require that the driver's position be on a particular side of a vehicle. Thus, it permits a vehicle to be either left-hand or right-hand drive. The issue raised by your letter is how our standards apply when a vehicle is both left-hand drive and right-hand drive, i.e., the vehicle has two driver positions.

The term "driver" is defined as "the occupant of a motor vehicle seated immediately behind the steering control system." See section 571.3. It is our opinion that the providing of a steering control system is ordinarily sufficient to create a driver's position, but that for vehicles with two driver's positions, the requirements specified in relation to the driver need be met only from the position intended by the original manufacturer as the primary driving position. However, if that manufacturer, or a subsequent converter, intends the driving positions to be used interchangeably under similar driving conditions so that neither driving position could be considered as primary over the other, then all Federal requirements would have to be met, e.g., the requirement in Standard No. 207 Seating Systems that a seat be provided for the driver.

We addressed this issue previously in a letter sent July 30, 1975 to Byron A. Crampton of the Truck Body and Equipment Association, Inc., in which the agency informed Mr. Crampton that a dual-control garbage truck that contained an auxiliary driver's position on the right side of the vehicle, with a separate set of controls, need not have a seat at the auxiliary position, and that access to such controls as the heater, wipers, and lights from this position was not required. Earlier, in an interpretation issued in 1968, with respect to driver education cars with dual controls, the agency considered the "driver, of such a vehicle to be the person seated behind the primary controls.

We appreciate your concern with safety that occasioned your letter. You may be reassured to know that the National Truck Equipment Association has had no reports of accidents or injuries due to the dual control feature of refuse trucks. However, it is possible that the agency could institute rulemaking in the future that would require a full set of controls and seats in dual control vehicles.

Your second question relates to noise standards. The in-cab noise standard is administered by the Department's Federal Highway Administration (FHWA). We have forwarded a copy of your letter to that agency's Office of Motor Carrier Safety so that they can respond to your question.

I hope that this information is useful to you.

ID: nht90-1.48

TYPE: INTERPRETATION-NHTSA

DATE: FEBRUARY 20, 1990

FROM: BARBARA J. KELLEHER-WALSH -- HARTLEY ASSOCIATES INC.

TO: HENRY J. NOWAK -- U.S. HOUSE OF REPRESENTATIVES

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-2-90 TO GEN. JERRY RALPH CURRY, NHTSA, FROM CONGRESSMAN HENRY J. NOWAK; ALSO ATTACHED TO LETTER DATED 8-22-89 TO DEIRDRE FUJITA, OFC. OF CHIEF COUNSEL FROM BARBARA J. KELLEHER-WALSH, HARTLEY ASSOCS. INC. AND LETTER DA TED 3-16-90 TO BARBARA J. KELLEHER-WALSH FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STD.213]

TEXT: Hartley Associates, Inc. is a woman-owned small business enterprise (WBE), certified by the State of New York, which is located in your Congressional District at 48 Heritage Court, Cheektowaga, NY 14225. The corporation was formed in 1986 for the purpos e of performing research, development, testing and evaluation in the field of automotive transportation safety and to provide consulting services to manufacturers of automotive restraint devices, both for children and adults.

In July 1989, Hartley Associates, Inc. was retained by Century Products Co., 9600 Valley View Road, Macedonia, Ohio 44056 for consulting services. Century Products Co. had recently developed an infant automotive restraint system equipped with a canopy s un visor (Model 580) and their concern was whether or not this design would meet the requirements of Federal Motor Vehicle Safety Standard Number 213 (FMVSS 213) - Child Restraints. We were requested to determine the FMVSS 213 requirements relevant to s un visors, perform whatever tests were deemed necessary and provide documentation ensuring that the Model 580 infant restraint complied with FMVSS 213.

Subsequently, we received two interpretations of FMVSS 213 regarding the use of sun visors which had been issued by the National Highway Traffic Safety Administration (NHTSA), Office of Chief Counsel (Mr. Dan Wilinsky, 12-31-86 and Mr. Bruce Smith, 6/4/8 7). Both of these interpretations stated that a sun visor attached to an infant restraint system must comply with FMVSS 213, Section 5.2.3.2. Two dynamic sled tests were performed according to the requirements of FMVSS 213 in August of 1989. The resul ts of these tests showed that the Model 580 infant restraint complied with FMVSS 213, Section 5.2.3.2.

On August 22, 1989, Ms. Deirdre Fujita, Office of Chief Counsel was requested to issue an interpretation of S5.2.3.2 of FMVSS 213 with regard to the Century 580 infant restraint system with sun visor. A informed me that a meeting between NHTSA and Hartl ey Associates, Inc. was not necessary and that she would issue a letter of interpretation based on the information and test results provided by Hartley Associates, Inc.. During this seven month period, I have contacted Ms. Fujita five times by phone and once in person. She has informed me that the letter of interpretation was issued shortly after receipt of our letter but has been 'held up' by the approval process and she cannot anticipate a date for issuance.

I would sincerely appreciate any assistance you can provide in expediting this letter of interpretation. The lack of timeliness of the receipt of this interpretation is having a negative impact on the reputation of Hartley Associates, Inc. to provide a timely response to the requests of a customer.

If you have any questions I can be reached by telephone at (716) 892-6313 of by telefax at (716) 897-0515.

ID: nht90-1.49

TYPE: Interpretation-NHTSA

DATE: February 20, 1990

FROM: H. Reese Chappell -- Engineer, Auto Ventshade Company

TO: Barry Felrice -- Associate Administrator for Rule Making, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-2-90 to R. Chappell from P. J. Rice; (A35; Std. 205 VSA S108(a)(1)(A); and photos (text omitted)

TEXT:

Auto Ventshade Company is a manufacturer in the automotive aftermarket business. As per my telephone conversation with your secretary, I am sending you a brochure which shows the application of our product, the Ventvisor.

We would like to know if there are any federal regulations on light transmission or otherwise which govern our product. The smoke-grey tinted Ventvisor has 47.5% light transmission which, as far as we have been able to determine, complies with state-to- state laws. We also manufacture a clear non-tinted part which we sell in California, New Jersey and West Virginia. These states do not allow any tinted products on automobiles at all.

Please send me written notice of any regulations that may exist so that we can be sure that our product complies completely with federal laws.

Thank you very much for your time. Your reply will be greatly appreciated.

ID: nht90-1.5

TYPE: Interpretation-NHTSA

DATE: 01/01/90 EST

FROM: Cal Karl -- District 4700, State of Minnesota, Department of Public Safety, State Patrol

TO: All School Bus LCR II's

TITLE: Re School Bus Vandal Locks

ATTACHMT: Attached to letter dated 11-27-90 from P.J. Rice to C. Karl (A36; Std. 217); Also attached to letter dated 12-7-82 from F. Berndt to M.B. Mathieson; Also attached to letter dated 1-29-90 from C. Karl to M. Shaw (OCC 4403); Also attached to lett er dated 1-18-90 from R.E. Meadows; Also attached to letter dated 1-8-90 from R. Marion to C. Karl

TEXT:

Please be aware that some buses are appearing in the inspection process with vandal locks that do not comply with regulations.

49 CFR 571.217 provides for a lock on emergency exits. Effective 7/1/89, State Rule 3520.5010 subp 2 provides for locks on emergency doors and service door if they comply with 217.

571.217 requires the lock to disable the engine starting system if any emergency exit is locked. It further requires the presence of a person with a key or combination to activate such a mechanism.

Do not accept a bus that has a vandal lock that does not comply with this regulation. If there are buses in your area that have such locks, please make every effort to contact the operator and require that the lock be brought into compliance or removed.

Please review the language in 571.217. (Attached)

ID: nht90-1.50

TYPE: Interpretation-NHTSA

DATE: February 20, 1990

FROM: David G. Dick -- Technician, Toy Laboratory, ACTS Testing Labs, Inc.

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-10-90 from P.J. Rice to D.G. Dick (A36; Std. 213)

TEXT:

This letter is to request an interpretation of the National Highway Traffic Safety Administration, Department of Transportation, Code of Federal Regulations, Title 49, Transportation, Part 571.213, S5.2.3 Head Impact Protection requirements.

Section 5.2.3.2(a) of the Standard requires a 25% compression-deflection resistance of not less than 0.5 and not more than 10 pounds per square inch (psi) when tested in accordance with Section 6.3 for the energy absorbing material.

The requirements of not less than 0.5 and no greater than 10 psi are listed in the standard to one significant figure, however, when specimens are tested in accordance with the specified methodology, the results are calculated to more than one significan t figure. Is it acceptable to round off the result to one significant figure as stated in the standard as seen in the below example?

i.e.: 0.47 would be rounded up to O.5 and reported as a Pass.

Additionally, how was the lower limit of 0.5 psi decided upon?

Is there any situation in which an energy absorbing material with a 25% compressiondeflection resistance of less than 0.5 psi acceptable?

Your quick response to these questions would be greatly appreciated.

ID: nht90-1.51

TYPE: Interpretation-NHTSA

DATE: February 20, 1990

FROM: Louis F. Wilson -- Instant Traffic Lights

TO: NHTSA, Department of Transportation

TITLE: Re Letter dated September 1, 1989.

ATTACHMT: Attached to letter dated 9-1-89 from Louis F. Wilson to NHTSA; Also attached to letter dated 3-8-91 from Paul Jackson Rice to Louis F. Wilson (A37; Std. 108); Also attached to letter dated 2-20-91 from Louis F. Wilson to NHTSA (OCC 5747)

TEXT:

We sent you a letter concerning the legality of our product, Instant Traffic Lights on September 1, 1989 and as of this date, there has been no reply. With the date of the availability approaching rapidly, we are left pondering about the situation. We would appreciated it if you would take a few moment of your time to review our product. Along with this letter, we will send you a copy of the letter we mailed to you on September 1, 1989. On the attached letter, there are few questions which we would like to know. We would be grateful if you could send us a reply in the near future. Thank you very much.